Case 1:20-cv-00484-JGK-DCF Document 79 Filed 09/04/20 Haddon, Page 1 of 3 and EIM r.c Laura A. Menninger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com Imenningeahmflaw.com HADDON AN tN September 4, 2020 VIA ECF Hon. Debra Freeman United States Magistrate Judge Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312 Re: Reply in Support of Letter Motion to Stay Proceedings 20-cv-484 (JGK-DCF), Jane Doe v. Darren K. Indyke, et al. Dear Judge Freeman: On behalf of defendant Ghislaine Maxwell, I write in further support of a Motion to Stay Proceedings in this matter until the conclusion of the criminal trial in United States v. Maxwell, 20 Cr. 330 (AJN) ("Criminal Case"). Plaintiff apparently concedes, by failing to respond, that (a) she is one of the three accusers mentioned in the Indictment in the Criminal Case, (b) substantial overlap, if not complete identity, therefore exists between the issues, witnesses and facts in the Criminal Case and her request for tens of millions of dollars from Ms. Maxwell in this case, (c) an indictment is legally "the most important factor" in a motion to stay parallel civil proceedings, (d) judicial economy will best be served by allowing the Criminal Case to proceed first, and (e) absent a stay, Ms. Maxwell will be forced to choose between her constitutional right to remain silent and her active and vigorous participation in defending against and refuting plaintiff's false claims in this case. Instead, Plaintiff argues that a stay would harm her (unspecified) interests and that litigating from inside the MDC under COVID-lockdown is "not [a] great" burden. Both arguments are borderline frivolous. No articulated harm to Plaintiff's interests: Despite proclaiming a stay will "harm plaintiff's interests," she fails to explain why. Ipse dixit aside, Plaintiff correctly explains that she can participate in the Epstein claims program while simultaneously pursuing